4 22 Corporate Park Irvine, CA JOHN DOE STORES 1-49 JANE DOES MANUFACTURERS JACK DOES DISTRIBUTORS JIM DOES MARKETERS JOAN DOES HEALTHCARE PROVIDERS JAKE DOES Defendants. ABBREVIATED INDIVIDUAL COMPLAINT FOR PPA LITIGATION AND ADOPTION BY REFERENCE 1. Plaintiff for her/his claim against the defendants states and alleges as follows and incorporates by reference the relevant portions of the Master Complaint on file entitled In re: New Jersey Superior Court PPA Litigation Case Code No.264, now pending in the Superior Court of New Jersey, Law Division, Middlesex County before the Honorable Marina Corodemus, J.S.C. Plaintiff selects and indicates by checking off the appropriate boxes, those products, parties and claims that are specific to her or his case. Where claims require, pursuant to New Jersey law, specific pleading or case specific facts and individual information, plaintiff shall add and include them herein. 2. Plaintiff, is an individual who resides at in the State of (hereinafter referred to as the?plaintiff?. On or about (date, Plaintiff was injured as a result of ingesting PPA containing product(s.

5 2A. Plaintiff brings this action: on behalf of himself or herself as the representative of. as the parent and guardian ad litem of, a minor born on. as the Administrator of the Estate of Plaintiff? s (hereinafter? Decedent? ; see Letters of Administration annexed hereto as Exhibit A, who died on. 2B. Plaintiff claims damages as a result of: Personal Injury to herself, himself, or the person represented Wrongful Death Loss of Consortium (per quod Loss of Services Economic Loss 3. Plaintiff/Decedent purchased and/or otherwise obtained and ingested the following: Robitussin CF Contac Alka-Seltzer Tavist-D Dimetapp Coricidin? D? Accutrim

6 Dexatrim Bayer Cough Syrup Chlor-Trimeton Sinus Tablets Comtrex Dristan Triaminic Tylenol Cold Medicine Vicks Day Quil Allergy Relief Other (Please identify what? product? 1. Plaintiff? s spouse, is an adult individual residing at in the State of (hereinafter referred to as? Spouse? and claims damages as a result of: Loss of Consortium, date of marriage. Wrongful Death, date of death. 5. The following entity(s are named as defendants as a consequence of plaintiff having suffered harm as a result of having ingested products containing PPA which were manufactured, promoted, distributed and/or sold by such defendant(s, and the allegations with regard thereto in the Master Complaint are herein adopted by reference: (Check appropriate defendants American Home Products Corporation Bayer Corporation Bristol-Myers Squibb Co.

9 *If you include a claim for medical malpractice, the facts supporting this count must be specifically pled by the plaintiff and the defendants against whom they are alleged must be identified on a separate sheet of paper attached to the Complaint. In addition, all obligations pursuant to N.J.S.A. 2A:53A-27 or any other statute applicable thereto apply and must be adhered to. *If Count IV or VII are checked off, the facts supporting this (these count(s must be specifically pled by the plaintiff and the defendants against whom they are alleged must be identified on a separate sheet of paper attached to the Complaint. Plaintiff asserts the following additional theories of recovery against the defendants identified herein: If you have included any additional theories of recovery, to the extent they require specificity in pleadings, the specific facts and allegations supporting these theories must be pleaded by the plaintiff in a manner complying with the requirements of the New Jersey Rules of Court. DEMAND FOR JURY TRIAL Demand is hereby made for a trial by jury. Attorneys for Plaintiff By: Dated: CERTIFICATION PURSUANT TO RULE 4:5-1 Plaintiff upon information and belief is not aware of any pending or contemplated action. Further, upon information and belief, she/he is not aware of any other party who should be joined in this action. Attorneys for Plaintiff

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